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#158735 - 02/10/04 06:14 PM Assessment Area
Summer101 Offline
Platinum Poster
Joined: Jun 2001
Posts: 644
If in researching our 2003 CRA data we determine that we really should change our assessment area, can we do that now in 2004 before the data is submitted ... or should board approval have been obtained in 2003? Thanks.

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#158736 - 02/10/04 06:59 PM Re: Assessment Area
BankerMama Offline
Diamond Poster
Joined: Jun 2001
Posts: 1,543
I'm not aware that board approval is required. In fact, examiners can even change your assessment area.

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#158737 - 02/10/04 07:09 PM Re: Assessment Area

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#158738 - 02/10/04 08:35 PM Re: Assessment Area
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
One year our examiners allowed us to change the AA before the end of the exam so they wouldn't have to criticize us. Go for it !
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.

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#158739 - 02/10/04 08:41 PM Re: Assessment Area
Sinatra Fan Offline
Power Poster
Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
Changing your AA as a result of self analysis is a proactive approach, one that I could not see examiners criticizing (ooh, there's a bold statement). If you are told to change your AA, that is reactive, and not generally looked upon favorably (another risky statement).
Management is doing things right; leadership is doing the right things. Peter Drucker

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#158740 - 02/10/04 09:07 PM Re: Assessment Area
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Basically, your Assessment Area is whatever you say it is when you submit your loan data and that Assessment Area should be reflected in your Public File.
Regulations are a poor substitute for ethics.
Just sayin'

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#158741 - 02/10/04 09:10 PM Re: Assessment Area
AnonRegulator Offline
Gold Star
Joined: Mar 2002
Posts: 451
Everywhere, USA
The CRA statute and regulation are both silent on this, so you may change your AA at any time. I don't think it is a good idea to do that on your own though. I'd get at least your supervisor's ok, if not the board's, but that isn't required either.

BTW, want to see your examiner become short of breath and clutch his/her chest? Just wait for them to get near the end of a CRA exam, particularly a large bank CRA exam, and just mention that, oh, by the way, did we tell you we changed our AA? AR.

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